City's Answer to Petition - PRCP-MI University Trails LLC - 26-001520.pdf
Prcp-Mi University Trails LLC Petitioner Vs. City Of Ann Arbor Respondent · 26-001520-TT
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STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL PRCP-MI UNIVERSITY TRAILS LLC, Petitioner, v. CITY OF ANN ARBOR, Respondent. MTT Docket No. 26-001520 Sarah R. Belloli RYAN, LLC Representative for Petitioner 101 West Big Beaver, Suite 945 Troy, Michigan 48084 (313) 230-0104 sarah.belloli@ryan.com John W. Reiser (P45050) OFFICE OF THE CITY ATTORNEY Attorney for Respondent 301 E. Huron Street, 3rd Floor Ann Arbor, Michigan 48104 (734) 794-6170 Jreiser@a2gov.org RESPONDENT CITY OF ANN ARBOR’S RESPONSE TO PETITION Respondent City of Ann Arbor (“Respondent”), through the Ann Arbor City Attorney’s Office, responds in opposition to the Petition of PRCP-MI UNIVSERITY TRAILS LLC (“Petitioner”) and states as follows: 1. Admit. 2. Admit. 3. No response required. 4. No response required. 5. No response required. 6. Admit. 7. Respondent leaves Petitioner to its proofs.
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2 8. No response required. 9. No response required. 10. Admit. 11. Admit. 12. Respondent leaves Petitioner to its proofs. 13. Respondent leaves Petitioner to its proofs. 14. Admit. 15. No response required. 16. Admit. 17. Respondent leaves Petitioner to its proofs. 18. Respondent leaves Petitioner to its proofs. 19. Respondent requests that the Tribunal deny Petitioner’s request (a) through (c) and affirm Respondent’s 2026 values. 20. Respondent denies subparagraphs A. and B. as untrue and leaves Petitioner to its proofs. For the reasons stated above, Respondent asks the Tribunal to deny Petitioner’s request and affirm 2026 assessed and taxable values. Dated: August 14, 2026 Respectfully submitted, OFFICE OF THE CITY ATTORNEY By: /s/ John W. Reiser John W. Reiser (P45050) Attorney for City of Ann Arbor 301 E. Huron Street, 3rd Floor Ann Arbor, Michigan 48104 (734) 794-6170 jreiser@a2gov.org
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3 AFFIRMATIVE DEFENSES Respondent City of Ann Arbor (“Respondent”), through the Ann Arbor City Attorney’s Office, and for its Affirmative Defenses to the Petition of PRCP-MI UNIVERSITY TRAILS LLC (“Petitioner”) states as follows: 1. Respondent reserves the right to raise affirmative defenses as the same become apparent in the course of this litigation. Dated: August 14, 2026 Respectfully submitted, OFFICE OF THE CITY ATTORNEY By: /s/ John W. Reiser John W. Reiser (P45050) Attorney for City of Ann Arbor 301 E. Huron Street, 3rd Floor Ann Arbor, Michigan 48104 (734) 794-6184 jreiser@a2gov.org PROOF OF SERVICE I hereby certify that I emailed a true and correct copy of the foregoing Response to Petition and Affirmative Defenses to the above-named petitioner’s representative at the address listed above this August 14, 2026. /s/ Dawn Bagozzi Legal Assistant